Seattle, WA and Vancouver, BC -- Four conservation groups from two countries have joined forces to launch an official objection to the Marine Stewardship Council’s (MSC) proposed re-certification of Alaskan salmon fisheries. Wild Fish Conservancy, from Washington State, along with the Watershed Watch Salmon Society, SkeenaWild Conservation Trust, and Raincoast Conservation Foundation, based in British Columbia (BC), say that the MSC eco-label is turning a blind eye to serious overfishing in Southeast Alaska.

The groups say that Alaskan fishermen intercept too many salmon from endangered populations as the fish migrate through Alaskan waters on their way to spawning grounds in BC and the continental US. The official objection focused on the Southeast Alaska “unit of certification” where the groups would like the MSC to apply conservation conditions that would address the overfishing of wild Chinook, sockeye, and chum salmon, and require fishermen to report the numbers of steelhead trout that they take as by-catch and keep or discard.

“The Alaskans are good at not overfishing their own wild salmon runs”, said Kurt Beardslee of the Wild Fish Conservancy, “and we’d just like to see them extend the same conservation ethic to some of these salmon runs in BC, Washington, and Oregon that are in serious trouble.“

“The Southeast Alaskan Chinook fishery is actually a fishery for non-Alaskan fish, and it harvests those fish at levels far surpassing what fisheries scientists consider a maximum sustainable yield”, said Aaron Hill of Watershed Watch Salmon Society. “People who buy Alaskan Chinook (or king) salmon need to know that they could actually be buying a fish that was from an endangered run in BC, Washington, or Oregon”, continued Hill.

“The third-party certifier hired by the fishing industry was essentially given permission by the MSC to pull some procedural sleight-of-hand”, said Greg Knox of SkeenaWild. “MSC let them consider the various Chinook runs exploited by the fishery as large groups, rather than looking at the status of the individual runs. This allowed the certifier to ignore the rampant overfishing of the endangered runs. They did it at the 11th hour, and without consulting stakeholders.”

The groups contrast MSC’s treatment of overfishing in Southeast Alaska with the Council’s more prudent stance on the Prince William Sound fishery, which was withheld from receiving the coveted blue eco-label, due to the massive, risky ocean-ranching operations that dominate that region of Alaska.

The Chinook salmon fishery is considered the most problematic, for its impacts on endangered runs. The report that MSC has accepted from the certifying body acknowledges that over 96% of Chinook salmon caught in the Southeast Alaskan fishery originate from rivers outside Alaska.

A native Oregonian, this iridescent looking chub has been the focus of a successful recovery effort over the last 20 years. (Thanks to Freshwaters Illustrated for the loan of this picture)

ODFW’s Native Fish Investigations Program (NFI) recently teamed up with the Molalla River Watch. The result – the first sighting of Oregon chub in the lower Willamette basin in 60 years.

In more good news for followers of this threatened native minnow, NFI staff recently discovered two populations of Oregon chub in the Molalla River Basin. Historically, Oregon chub occupied the Willamette River from the mouth of the Clackamas to the Coast Fork and Middle Fork of the Willamette River. However, the last observation of Oregon chub in the lower Willamette was at Oregon City in 1953. Since 1991, ODFW’s Native Fish Investigations Program has conducted surveys at over 50 locations in the lower Willamette in an attempt to locate this species, without success.

In 2013, NFI partnered with the Molalla River Watch to identify and survey additional locations in the Molalla River basin. Oregon chub were found at two sites, one on Milk Creek near the town of Canby, the other near the town of Molalla.

Oregon chub had not been documented in the Molalla basin previously. This finding extends the range of Oregon chub 70 river miles north. Although populations were historically documented below Willamette falls, the current known distribution is close to the historical distribution of Oregon chub.

Nonnative fish species, such as largemouth bass and bluegill, predate upon and compete with Oregon chub, and are common in the off-channel and slow flowing habitats preferred by chub. The impact of nonnative fish, combined with the alteration or loss of many off-channel habitats and changes in river flow due to the construction of the Willamette dams, led ODFW to believe that Oregon chub were likely extirpated from the lower Willamette

NFI staff are planning to seek out and collaborate with partners in the Molalla basin in 2014 and beyond to sample additional areas. In addition, NFI will seek out public and private landowners that are willing to allow introductions of Oregon chub into suitable habitat, to increase the number of populations and add resiliency for the species.

Effect of Stocking Non-Native Trout on Native Nongame Fish Species

Abstract

Fisheries managers are faced with the challenge of balancing the management of recreational fisheries with that of conserving native species and preserving ecological integrity. The negative effects that nonnative trout species exert on native trout are well documented and include alteration of competitive interactions, habitat use, and production. However, the effects that nonnative trout may exert on nongame fish assemblages are poorly understood. Our objectives were to quantify the effects of trout stocking on native nongame fish assemblages intensively on one newly stocked river, the North Toe River, North Carolina, and extensively on other southern Appalachian Mountain streams that are annually stocked with trout. In the intensive study, we adopted a before–after, control–impact (BACI) experimental design to detect short-term effects on the nongame fish assemblage and found no significant differences in fish density, species richness, species diversity, or fish microhabitat use associated with trout stocking.

We observed differences in fish microhabitat use between years, however, which suggests there is a response to environmental changes, such as the flow regime, which influence available habitat. In the extensive study, we sampled paired stocked and unstocked stream reaches to detect long-term effects from trout stocking; however, we detected no differences in nongame fish density, species richness, species diversity, or population size structure between paired sites. Our results revealed high inherent system variation caused by natural and anthropogenic factors that appear to overwhelm any acute or chronic effect of stocked trout. Furthermore, hatchery-reared trout may be poor competitors in a natural setting and exert a minimal or undetectable impact on native fish assemblages in these streams. These findings provide quantitative results necessary to assist agencies in strategic planning and decision making associated with trout fisheries, stream management, and conservation of native fishes.

of rainbow trout) in Mann Creek and Reservoir, southwestern Idaho, continues to undergo smoltification. This

population had an anadromous component before the construction of main-stem and tributary dams in 1958 and

1967, respectively.

Smoltification was assessed by quantifying the proportion of juvenile migrants that displayed high skin reflectance, comparing mean gill Na+,K+-ATPase activity among migrants, and examining migration timing compared with that of neighboring steelhead (anadromous rainbow trout) populations. Approximately one-quarter of the 1,502 juvenile migrants trapped and examined displayed the intermediate or high skin reflectance (nonbanded silvery coloration) characteristic of smolts; the other fish maintained a banded coloration more typical of resident fish. For 78 samples of gill filaments over the course of the migration season (18 March to 3 June), Na+,K+-ATPase activity varied considerably among fish (0.95–5.81 μmol Pi · h−1 · mg protein−1) and doubled in nonbanded fish over the course of the migration period. ATPase activity was significantly higher for nonbanded fish than for banded fish at the end of the migration period (21May – 4 June). Juvenile adfluvial redband trout migrated from Mann Creek in approximate synchrony with neighboring steelhead populations. These results suggest the possibility that in areas in the Snake River drainage where steelhead have been extirpated as a result of artificial barriers, remnant populations retain the potential for anadromy.

Discussion:

“Genetic studies have identified genome regions associated with smoltification traits (e.g., Nichols et al. 2008); however, the studies did not provide clear evidence that smoltification or anadromy is genetically controlled. Thrower and Joyce (2004) found that an isolated rainbow trout population in Alaska continued to produce smolts even though a barrier that had blocked their return migration for 70 years imposed strong selection against emigration from the lake. Thrower and Joyce (2004) nevertheless found that anadromous parents produced more

anadromous offspring than did resident parents in laboratory studies. Furthermore, Thrower and Hard (2009) found that migrant progeny of resident O. mykiss had much lower marine survival rates than migrant progeny of anadromous parents, and Pearse et al. (2009) found that relatively few resident O.mykiss successfully completed an anadromous life cycle. Although smoltification is a necessary process for salmonids to complete an anadromous life cycle, it is only one of many factors that determine whether a fish can successfully migrate to and from a marine environment.

(Kozfkay et al. 2009). These stockings may have led to introgression of native and hatchery fish. Genetic analyses indicated that fish sampled from Mann Creek Reservoir were introgressed (Matt Campbell, Idaho Department of Fish and Game, unpublished data), while fish sampled in the headwaters of Mann Creek did not show signs of introgression (Kozfkay et al. 2011). There is evidently a barrier that prevented hatchery fish from introgressing with the headwater populations. However, it is unknown whether the putative smolts in our study are derived from the introgressed population, the pure population, or both populations. Future studies should examine genetic differences

between the banded and nonbanded fish in this study as they could provide important information regarding smoltification traits and capabilities in O. mykiss.

“Our results suggest the possibility that in portions of the Snake River drainage where steelhead have been extirpated as a result of artificial barriers, remnant populations may retain the potential for anadromy if migratory paths were reconnected. To fully interpret the evidence presented here that an isolated redband trout population continues to undergo morphological, physiological, and behavioral changes associated with smoltification, future research should examine other O. mykiss populations, especially those in more interior regions, that have been blocked from migration for much longer periods of time. Examining populations with a longer history of isolation from marine environments could be useful for understanding the persistence of smoltification capabilities as well as other co-occurring aspects of redband trout life history.”

Adfluvial Redband Trout Population Upstream from an Impassable Dam: Does It Persist?, Transactions of the American Fisheries Society, 141:1, 68-75, DOI: 10.1080/00028487.2011.651550

HOW AGENCIES DEFEAT PUBLIC INITIATIVES

INSTITUTIONAL SELECTION

We have all heard of natural selection, a concept created by Charles Darwin in 1859. It is the primary way in which animals and plants adapt to their environments through sexual reproduction.

There is another form of selection having to do with cultural forces, a system of beliefs, assumptions, and values. Institutional selection imposes compliance among people in agencies and business. If one wants to rise within the institution a clear record of compliance to institutional values and beliefs is required. These selective factors are often unspoken, but those who want the institutional rewards are nonetheless very much aware of them.

Public agencies are influenced by having to be responsive to public concerns and involve the public in policy development. The problem for the agency is that the public can interfere with agency culture. They are constantly having to deal with public proposals and are obligated to hold public hearings on issues that can result in agency change. For this reason public agencies have developed a sophisticated resistance to outside interference. As one administrator once told me if you poke us too much in one direction, we build a callus.

The first level of resistance comes when the agency is confronted with a policy change over how it administers its system of assumptions, beliefs and values. Public initiatives arrive without invitation from outside the agency. As one director of the Oregon fish and wildlife department once said, “We can recover salmon if the public would just stay out of our business.” This candid burp was rather revealing for its honesty.

Public agencies are also burdened with a commission that can, when they feel forced, be responsive to public initiatives to change agency policy. The commission is always a wild card that the agency staff is constantly worried about, for it could mean a reflexive change in the way things are done, so they spend a lot of time tuning the commission up to support staff’s natural abhorrence to any change whatsoever. But change happens and the agency has developed a way to slow change down and defeat it, if given enough time.

The first thing that staff does with cooperation of its legal department is make sure that any policy change has no clauses of accountability embedded in it, something the public can use to pester the agency about non-compliance through the courts. So all policy changes are cleansed of deadlines, deliverables, numerical values or anything else that the public can use to threatened the status quo of agency operations.

Another useful tactic is to know your public. This is necessary because the agency is often called upon to assemble a public advisory group to help in the process of policy development. A useful precautionary tactic is to stack public advisory groups with people who are supportive of the agency status quo, but to appear non-partial they appoint one or at the most two people who are progressive in their views knowing they can be controlled or out voted. A novel refinement of this tactic is to invite people who are opposed to the agency altogether. They are useful in creating conflict with the feared change makers giving the agency the middle ground. For example, when deciding the Native Fish Conservation Policy, the ODFW invited the private property advocates to the table. These folks were opposed to fish protection because they believed private use of land was threatened. Including them on a committee to develop conservation plans for the protection of native species ensured conflict. This was an unusually perceptive adjustment by staff to protect the agency status quo for it created a strong opposition to those seeking an effective conservation policy and at the same time gave the agency staff the middle ground. The staff ran shuttle diplomacy between the two opposing groups in the committee, telling each one what they wanted to hear, thus strengthening the conflict. This increased the agency capacity to maintain the status quo.

Another artful dodge is to maintain a policy in draft form for as long as possible so that it is not binding on the agency and no matter how hard the public might press them to implement the policy, the agency reminds them that it is only a draft.

These tactics are for the single purpose of protecting the agency from change, especially those threats generated by outsiders, the public.

Once a policy development committee is seated, it is obvious to the agency staff that change is inevitable, so additional tactics are necessary to slow change down.

The second level of resistance is to not implement or make implementation impossibly slow so that those wanting change get busy on other things and public pressure is dissipated. Too often the public assumes that once a policy is adopted by the agency and becomes administrative law, that the agency will practice due diligence and implement that policy. The public spends a lot of time in policy development but attention wanes when it comes to carrying out the policy on the ground.

When the Oregon department of fish and wildlife adopted the Oregon Wild Fish Management Policy in 1978 and revised it several times later to remove legal handles that could prove inconvenient, it was discovered that the policy was not actually being applied agency wide. The policy was never popular and it was left up to staff to implement if they wanted to do so. The environmental advocates for this policy assumed that it was being applied across the state to provide protection for wild fish and were shocked to find out that it was an elective.

When the public was successful in convincing the commission to implement a slot regulation for Deschutes River trout fishery, one agency administrator complained that ODFW no longer managed the Deschutes, the public did. The slot regulation did away with bait and allowed a restricted kill of trout in number and size. This led to a catch and release fishery, which is not favored by an agency that believes a kill fishery is the only way to sell licenses.

The following is provided to show just how strong resistance to institutional change can be. The Oregon Legislature passed a state law that said it is the overriding obligation of the fish and wildlife department and commission to “prevent the serious depletion of any indigenous (native) species.” Serious depletion was not defined so the agency had plenty of interpretation room to avoid compliance. The ODFW commission got into the act and said that the law also directed the agency to provide social benefits and concluded that conservation is balanced by the requirement to provide those benefits such as harvested fish. They developed a code for killing fish called “fishing opportunity.”

At the request of the public, the Oregon Attorney General’s office provided the ODFW with its assessment of this statute in 1997 and again in 2003. In those legal reviews the agency was told that its “overriding obligation is to prevent the serious depletion of indigenous species” and the agency is unable to provide social benefits unless this happened. Thus, the balancing argument of the ODFW commission was set aside, but their dedication for it was not.

Also at the public’s request, the ODFW director distributed the 1997 legal opinion from the AG’s to the staff so they would be fully informed about the law and their obligation to it. However, this law did not mesh well with the understood institutional mission of the agency by staff. One did not advance their careers by being an advocate for wild fish. One staff person who left ODFW told me he left because he did not like getting in trouble for following the rules.

In 2003 the AG’s office once again reminded the agency of its overriding obligation to protect native species from serious depletion as they sought to adopt the Native Fish Conservation Policy. In 2013 this state law still has no real traction within the agency in their day to day management. It was disturbing when a commissioner told me that he did not know how to deal with this responsibility.

It can be argued that when the state assigns a species as sensitive, which means it is precarious and vulnerable to extinction, or when a species is provided protection under the federal Endangered Species Act, that it is certainly seriously depleted. With regard to ESA-listed species, the states must get coverage from the National Marine Fisheries Service to run its hatchery and harvest programs. This would appear to be a serious check on any agency’s institutional mission, but it isn’t, for even though the federal agency requires the agency to justify its actions, it is not often different from what the agency would have done anyway. The only difference is the additional paper work.

In the state of Washington, the WDFW commission adopted a Wild Salmonid Policy. The director that led this adoption struggle and the staff person that drafted the policy lost their job soon after this policy was adopted. Since its adoption, the agency has quietly ignored it for it requires change in hatchery and harvest structures that have been in place a long time, serving the interests of its constituent groups.

More recently, the WDFW commission adopted a Wild Steelhead Management Plan. This plan calls for Wild Steelhead Management Zones to be adopted. The public requested this and was successful. However, when asked why there has been little movement in setting up Wild Steelhead Management Zones, including the 20 that the public recommended, they are given a number of reasons.

The first artful dodge is that this policy is still in draft form so it is not binding on the agency. That reasoning inflames the public so other reasons had to be found. Since their co-managers, Native American tribes, did not sign this policy, the agency cannot implement it. That is a better excuse because someone else is to blame. When reminded that the WDFW has an obligation to secure 50% of the available harvest for its constituents in a shared resource with the tribes, there is ample room to provide for wild steelhead management zones. When the public advocates are willing to forgo harvest to increase the spawner abundance of steelhead in these WSMZs it is unreasonable to allow the tribes to harvest the forgone and so-called surplus from the recreational fishery. But because the agency does not establish a steelhead harvest management plan prior to the fishery starting, it claims the agency is no power to make changes to protect spawners and achieve spawner escapement goals in each river that is co-managed. So the agency, by not doing its job creates an excuse to harvest all the fish, including those needed for spawning. In order to do this and still appear to be managers of good faith, the recreational fishery is closed while the tribal fishery continues to fish. The conclusion is that wild steelhead are not getting the needed protection.

In lower Puget Sound, hatchery fish harvest zones were created to maximize the harvest of hatchery coho. Wild coho spawner objectives by watershed have not been established because that would interfere with the harvest of hatchery fish. The petition to list wild coho in Puget Sound by the public was an attempt to correct this problem. By not protecting wild spawner abundance the WDFW is ignoring the best available science that has been in place for 72 years following the research of Willis Rich.

The conflict over conservation of native wild fish populations is created by the fish management agencies. As one retired ODFW biologist told me, wild fish and their habitat are irrelevant to the agency. They manage by a simple model of stocking hatchery fish and running kill fisheries. If one challenges that, one threatens the institution that is based on an industrial model of production and consumption where wild fish are considered a constraint on commodity production.

Fish and wildlife agencies have developed an elaborate resistance to changing their institutional structure of beliefs, assumptions and values. Even though they are public agencies they have created proven ways to blunt the effect of public reform efforts. They have rationalized state laws when they are in conflict with agency operations. They are able to do this because elected officials such as legislators, Congress, and governors, are not interested in resolving the problem. Elected officials and the public continue to provide public agencies their comfort zone by being ineffective advocates for accountability. As Jack Ward Thomas said when he became Chief of the U.S. Forest Service, public agencies should follow the law and tell the truth.

The public makes its demands and it can have a modest effect on the institutional culture of fish management, but unless the public is fully engaged constantly, agencies find a way to step around and reduce the effect of the changes. The public cannot assume the management agency will follow through on its commitments, tell the truth or follow the law, and for that reason, the public needs to be organized so that it is applying pressure constantly year after year to make sure conservation policies are implemented. The federal court is often used to reform public institutions, but judges often defer to apparent agency expertise and discretion.

Most public groups are themselves not organized to be vigilant protectors of Nature. For one thing policy development and accountability do not sell as well to foundations as do “shovel ready” short term action projects that have a short life span. Environmental groups need to make a commitment to follow through on policy development and implementation and find the donors that will help make that commitment a real force for conservation. The other important thing to do is work to elect public officials that actually care about how the state and the nation is protecting the environment and to have elected officials leverage the public’s concern for protecting nature.

Lacking that commitment, public groups are constantly fighting a rear-guard action plan and responding to crisis issues. This means that the agencies will not be reformed, and in the case of salmon, wild native species will not be recovered and there will be no end of populations being listed as endangered species and the rapid rate of extinction will not be addressed. Public agencies are organized to serve the narrow interests of their constituents rather than maintain the productivity and benefits of natural resources they are charged with protecting for the public good.

Recommended Reading:

Jim Lichatowich, Salmon, People and Place

Jim Lichatowich, Salmon Without Rivers

Lichatowich and Williams, Failure to incorporated science into fishery management (see the Native Fish Society web page for this article)

Rick Scarce, Fishy Business

The Alternative:

As wild salmonids continue to decline and go extinct, the fishery (hatchery and wild) will decline for the loss of genetic and life history diversity will make hatchery production less effective and more costly. The U.S. Fish and Wildlife Service has already said that the cost of hatchery production and lack of money will mean closures. This agency has already abandoned Atlantic salmon reintroduction in the Connecticut and Merrimack rivers because the results are too expensive. But there is an alternative that is drawing more anglers: Carp. More fly shops carry flies for them. Once called the “Queen of Oregon Waters” the carp have proven to be resilient and have expanded their range from the Columbia River to Malheur Lake. As the salmonids decline a new outlet has been found for the intrepid angler. Their squeals of delight can be heard on lowland ponds and streams as they hookup with the great golden fish. Some who have watched the decline of salmonids are hoping the state fishery agency doesn’t adopt a management plan for carp.

Since 2011, the Washington Department of Fish and Wildlife (WDFW) have been developing steelhead management plans for the lower Columbia River. These plans “reflect” the goals of the Statewide Steelhead Management Plan (SSMP). One aspect of these plans is to identify rivers that will be managed as wild steelhead gene banks. The SSMP requires that “at least one wild stock gene bank will be established for each major population group in each distinct population segment (DPS).”

The SSMP requires the following: “Establish a network of wild stock gene banks across the state where wild stocks are largely protected from the effects of hatchery programs.” Each gene bank will be managed on the criteria, (1) the stock is self-sustaining, (2) no hatchery releases were wild steelhead spawning or rearing takes place, and (3) fisheries will be allowed providing wild steelhead management objectives are achieved and it meets ESA requirements.

The WDFW determined which river meets the criteria of the SSMP for steelhead, three candidate rivers were identified as potential gene banks. The agency selected public advisory groups to help in this process. The Native Fish Society has participated in two of these advisory groups. The first effort resulted in the proposed designation of Wind River wild summer steelhead as a gene bank. The second groups has been working to designate the East Fork Lewis River as a wild winter and summer steelhead gene bank, and proposed protection of some areas in the Washougal River.

Plans will be provided for public review and comment, and then the agency will make a decision on which these rivers are designated by mid-2015.

The question is whether this approach is adequate to protect biological diversity of wild steelhead? Brian Riddell (author of the British Columbia Wild Salmonid Policy) in an interview on the need for gene banks for salmonids (1991) said, “We can no longer say we’re going to save ‘as much as possible.’ “That sort of compromise mentality got us into the trouble we are in now.”

The WDFW provides an answer, saying, “The Department believes the recommendations to establish gene banks in the three rivers identified…will further protect and enhance wild steelhead populations…while still providing a diversity of fishing options.”

The key points in play are that the least disruption there is to the status quo is good and that WDFW “believes” the three gene banks will protect wild steelhead, but they are not certain.

The lower Columbia River steelhead populations included in this gene bank proposal include the Cowlitz to the Wind River. There are five winter steelhead and three summer steelhead populations in this group of rivers.

Wild Steelhead Management Streams

Existing wild steelhead management areas include the N.F. Toutle above the Sediment Retention Dam and is closed to fishing. This stream was severely affected by the eruption of Mt. St. Helens in 1980. Also, the Wind River is managed as a wild summer steelhead gene bank and hatchery releases were terminated in 1997. The WDFW proposes to continue the gene bank management for Wind River summer steelhead.

There are no wild winter steelhead populations managed as a gene bank and all are exposed to hatchery fish impacts.

Hatchery Impacts by River

Green River is a tributary of the N.F. Toutle River. The habitat in this watershed was relatively unaffected by the eruption of Mt. St. Helens and supports the majority of the steelhead. Non-native (Skamania Hatchery) summer steelhead are released into this river (25,000). It is recommended that the hatchery summer steelhead program be terminated. The rationale is that a weir would not have to be built to reduce impacts from hatchery summer steelhead on wild winter steelhead, and it would prevent straying of non-native hatchery summer steelhead above the Sediment Reduction Dam on the N.F. Toutle that is now managed for wild winter steelhead.

S.F. Toutle River is currently getting a release of non-native (Skamania Hatchery) summer steelhead. WDFW did not provide the number of hatchery fish released nor did they explain why these hatchery fish would not stray above the Sediment Retention Dam on the N.F. Toutle and compromise the integrity of that wild winter steelhead management area.

Coweeman River, another Cowlitz tributary was excluded from consideration as a winter steelhead gene bank by WDFW without biological explanation.

E.F. Lewis River is presently subject to releases of 15,000 (Skamania) hatchery summer steelhead and 60,000 non-native (Skamania Hatchery) winter steelhead smolts. The required action is to terminate the release of both hatchery winter and summer steelhead in the E.F. Lewis, making it a wild steelhead gene bank.

Washougal River: Increase hatchery summer steelhead releases from 60,000 to 70,000 smolts and hatchery winter steelhead releases from 60,000 to 85,000 smolts. Washoughal River above Dougan Falls will be managed as a summer steelhead sanctuary and a new weir on the W.F. Washoughal River would prevent hatchery steelhead from spawning with wild summer steelhead in that stream.

The rationale provided by WDFW is to “minimize impact on harvest opportunity,” and to provide fishing opportunity in gene bank rivers as allowable. WDFW did not provide a scientific analysis regarding impacts on wild steelhead from their increased hatchery releases in non-gene bank rivers.

While there is support for zoning rivers so that a few out of many are managed for conservation and protection of wild salmonids the issue remains the impact on the biological diversity and reproductive success of wild salmonids in rivers under the industrial model to maximize production and product consumption. Are the non-gene bank rivers now managed as sacrifice zones for wild salmonids? It is likely that the biological diversity and productivity of wild salmonids will be degraded in sacrifice zones, even though the fish are protected under the federal ESA. This outcome is not logical from a biological perspective and the motive for doing it is suspect. Riddell said that this kind of “compromise mentality got us into the trouble we are now in now.”